· 10/24/2023
State ex rel. Payne v. Rose
Citations
- 174 Ohio St. 3d 162
- 235 N.E.3d 392
- 2023 Ohio 3801
Syllabus
Mandamus—Public-records requests—R.C. 149.43—When requested record is provided to requester by public office prior to instituting action, requester does not have a cognizable claim in mandamus—Writ and request for statutory damages denied.
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that attorneys did not have third-party standing to assert the rights of hypothetical and unascertained future clients
- holding that third-party standing requires (1) a close relationship to the right-holders, and (2) the right-holders must face hindrances to asserting their rights
- concluding that “a future attorney-client relationship with as yet unascertained Michigan criminal defendants” was insufficiently close because the relationship was hypothetical
- holding that attorneys did not have third-party standing to assert the rights of hypothetical and unascertained future clients
- holding that attorneys lacked third party standing to assert the rights of future, as yet unascertained clients with whom “they ha[d] no relationship at all”
- concluding that a “future attorney-client relationship with as yet unascertained” criminal defendants is not only not a close relationship but “no relationship at all”
Source: CourtListener parenthetical corpus (CC0).
Judges: Per Curiam
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.